Last Updated: June 18, 2021
We at BrightSpire Capital, Inc., and our affiliated companies (collectively, "we", "us", "our" and "BRSP") respect your concerns about privacy. This Privacy Notice applies to personal information we may obtain through this website (the "Site") and other personal information that we may collect in the course of our business.
This Privacy Notice describes the types of personal information we may obtain, how we may use the information, with whom we may share the information (including where they are located), how long we will retain the information and your choices regarding our use of the information. We also describe the measures we take to safeguard the information and tell you how to contact us about our privacy practices.
Click on one of the links below to view the listed section:
This privacy notice is published by BrightSpire Capital, Inc., its various affiliated companies and other entities that collect personal information through this Site or otherwise in the course of their businesses.
We obtain certain personal information (such as name and other contact details) directly from you when you choose to provide it through our Site or in the course of our business relationship – such as when you send us an email. The types of personal information we may obtain include:
Unless we explain otherwise at the time, providing personal information that we request is optional and any disclosures are made voluntarily.
We collect certain information by automated means when you visit our Site or premises or open our emails – this may include, for example, information as to how many users visit our Site, the pages accessed or images collected by closed circuit television, and whether you opened or clicked the links in our emails.
We collect this information through various means such as "cookies," "web beacons," collection of IP addresses and closed circuit television, as explained below and in our separate Cookies and Tracking Technologies Policy.
Our premises may use closed circuit television (CCTV) systems to monitor and record activity in the public spaces of our premises. The purposes of this monitoring and recording is to provide a safe and secure working environment for staff and visitors and to protect our property. Cameras are only used in public spaces. Should an incident occur, the recordings will be provided as evidence to the police or other law enforcement to assist with their inquires.
If you are involved in a business relationship with us we may also obtain some limited information about you indirectly, for example when your colleagues give us your contact details and information about your role, or from publicly available sources such as the Internet and/or subscription based services.
We may use the information described above to:
In addition, we may use information collected online through cookies and other automated means to manage our business. We also may use this information to help diagnose technical and service problems, administer our Site, and identify users of our Site. We may use clickstream data to determine how much time users spend on web pages of our Site, how users navigate through our Site, and how we may tailor our Site to better meet the needs of our users.
We also may use the information we obtain about you in other ways for which we provide specific notice at the time of collection.
Our Site is not designed to respond to "do not track" signals received from browsers.
In some countries, we need to identify the legal basis upon which we process your personal information. In general, we can process your personal information lawfully because we have a legitimate interest in doing so, to pursue the purposes that we have set out above. We may also occasionally need to process your personal information in order to perform our legal obligations.
We do not sell or otherwise share personal information about you, except as described in this Privacy Notice. We may share personal information with third parties (e.g. service providers) who perform services on our behalf. These third parties are not authorized by us to use or disclose the information, except as necessary to perform services on our behalf or comply with legal requirements. We may also share the personal information we obtain with our affiliates or subsidiaries.
We also may disclose information about you (i) if we are required to do so by law, regulation or legal process (such as a court order or subpoena), (ii) in response to requests by government agencies, such as law enforcement authorities, (iii) for the purpose of or in connection with legal proceedings, or otherwise for the purpose of establishing, exercising or defending our legal rights, or (iv) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity. We also reserve the right to transfer any information we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution, liquidation or other corporate event).
The disclosures of personal information referred to above include transfers of personal information which is subject to European Union data protection laws to countries outside the EU, the Cayman Islands Data Protection Law, California Consumer Protection Privacy ("CCPA") and various other worldwide privacy regulations. CLNY is an international group of companies, headquartered in the U.S., and it has affiliates and service providers, and relationships with counterparties and governmental authorities, all over the world. This includes transfers to countries, such as the U.S., which are not regarded by the European Commission as ensuring an adequate level of data protection. Where we transfer personal information to our service providers or affiliated companies in those countries, we do so on the basis of data transfer agreements designed to protect the privacy of your information, in forms approved for this purpose by the European Commission.
The period for which we will keep your personal information varies depending on the information and how we obtained it. Personal information will not be held for longer that it is needed, given the purposes for which it is held. Further information regarding our record-keeping policies is available upon request.
When you give us your contact details through our Site, we offer you certain choices about how we communicate with you and what information we collect from you. You also have the right under data protection law to require us to correct any inaccurate information that we hold about you or to obtain copies of the personal information we hold. You also have rights, in some circumstances, to object to our processing of your personal information and to require us to delete, or restrict our processing of, information we hold about you. You also have right, subject to applicable law, to request us to delete your personal information from our database. To update your online preferences, ask us to remove your information or submit a request, or if you would like a copy of one of the data transfer agreements referred to in Information We Share above, please contact us as indicated in the How To Contact Us section of this Privacy Notice.
You may unsubscribe from our email mailing list at any time by clicking on the unsubscribe link that is included in every promotional email that we send to you.
Our Site may contain links to other websites for your convenience and information. These websites may be operated by companies not affiliated with CLNC. Linked websites may have their own privacy policies or notices, which we strongly suggest you review if you visit any linked websites. We are not responsible for the content of any websites that are not affiliated with CLNC, any use of those websites, or the privacy practices of those websites.
We take all reasonable precautions in accordance with applicable law, including implementing administrative, technical and physical safeguards, to protect your personal information against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.
This Privacy Notice may be updated periodically to reflect changes in our personal information practices. We will post a prominent notice on our Site to notify you of any significant changes to our Privacy Notice and indicate at the top of the notice when it was most recently updated.
If you have any questions about this Privacy Notice, or if you would like us to update information we have about you or your preferences or exercise the other rights described in this Privacy Notice, please contact us at:
BrightSpire Capital, Inc.
590 Madison Avenue, 33rd Floor
New York, NY 10022
Attention: Chief Compliance Officer
Subject to certain limits under California law, California residents may ask us to provide them with (1) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and (2) the identity of those third parties. To obtain this information, please send a letter to the contract address set forth above with "California Shine the Light Privacy Request" in the subject line and in the body of your message.